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EU/UK GDPR Privacy Notice

Last Updated: November 26, 2025

Table of Contents

Introduction

This EU/UK GDPR Privacy Notice supplements our main Privacy Policy and provides specific information required under the European Union General Data Protection Regulation (EU GDPR) and the United Kingdom General Data Protection Regulation (UK GDPR) for individuals located in the European Economic Area (EEA) or United Kingdom.

This Notice should be read together with our main Privacy Policy, which contains comprehensive information about how we collect, use, and protect your personal information. This Notice provides additional details specific to GDPR requirements, including your data subject rights and our legal bases for processing.

Scope: This Notice applies to personal data of individuals located in the EEA or UK that we process in connection with our services, regardless of where Becoming Alpha, Inc. is located.

Data Controller Information

Data Controller: Becoming Alpha, Inc., a Delaware corporation headquartered at 8000 Avalon Boulevard, Suite 100, Alpharetta, GA 30009, USA, is the data controller for personal data processed in connection with our services.

Data Protection Officer: We have appointed a data protection officer (DPO) to oversee our data protection practices. You can contact our DPO at:

Email: privacy@becomingalpha.world
Subject Line: "Data Protection Officer"

Categories of Personal Data

We process the following categories of personal data, as defined under GDPR:

Identity Data

  • Name, date of birth, government-issued ID numbers, ID documents
  • Business information (for business accounts)

Contact Data

  • Email address, phone number, mailing address

Financial Data

  • Payment information, transaction history, wallet addresses
  • Bank account details (if applicable)

Technical Data

  • IP address, device information, browser type, operating system
  • Usage data, log files, cookies and similar technologies

Profile Data

  • Account preferences, username, profile information

Marketing and Communications Data

  • Marketing preferences, communication preferences

Special Category Data

We generally do not process special category personal data (e.g., data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data) unless required by law or with your explicit consent.

Purposes of Processing

We process your personal data for the following purposes:

Service Delivery

  • Providing access to our platform and services
  • Processing transactions and payments
  • Managing your account

Legal and Regulatory Compliance

  • Identity verification (KYC/KYB)
  • Anti-money laundering (AML) compliance
  • Sanctions screening
  • Tax reporting and compliance

Security and Fraud Prevention

  • Detecting and preventing fraud, abuse, and security threats
  • Maintaining platform security
  • Investigating suspicious activity

Service Improvement

  • Analyzing usage patterns and platform performance
  • Developing new features and services
  • Improving user experience

Communications

  • Responding to your inquiries and support requests
  • Sending service-related communications
  • Marketing communications (with your consent or where permitted by law)

Your Data Subject Rights

Under GDPR, you have the following rights regarding your personal data:

1. Right of Access

You have the right to access and receive a copy of your personal data that we hold. You can request access by contacting us at privacy@becomingalpha.world.

2. Right to Rectification

You have the right to have inaccurate personal data corrected and incomplete data completed. You can update some information directly through your account settings, or contact us for assistance.

3. Right to Erasure ("Right to Be Forgotten")

You have the right to request deletion of your personal data in certain circumstances, such as when:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent and there is no other legal basis for processing
  • The data has been unlawfully processed

However, we may be required to retain certain data to comply with legal obligations (e.g., AML/KYC retention requirements).

4. Right to Restrict Processing

You have the right to restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

5. Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.

6. Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests.

7. Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

8. Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect you. We generally do not make such decisions, but if we do, we will inform you and provide an opportunity to contest the decision.

Exercising Your Rights

To exercise your rights, please contact us at privacy@becomingalpha.world. We may need to verify your identity before processing your request. We will respond to your request within one month (may be extended to two months for complex requests).

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

  • Compliance with legal obligations (e.g., AML/KYC retention requirements of 5+ years)
  • Resolution of disputes and enforcement of agreements
  • Legitimate business interests (e.g., fraud prevention, security)

For detailed information about our data retention practices, please see our main Privacy Policy.

International Data Transfers

As a U.S.-based company, your personal data may be transferred to and processed in the United States and other countries outside the EEA/UK.

Safeguards: We ensure that international transfers are subject to appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses for transfers to processors and controllers outside the EEA/UK
  • Adequacy Decisions: We rely on adequacy decisions where applicable
  • Other Safeguards: We implement additional technical and organizational safeguards to protect your data

For more information about our international transfer safeguards, please contact us at privacy@becomingalpha.world.

Right to Lodge a Complaint

If you believe that our processing of your personal data violates GDPR, you have the right to lodge a complaint with your local supervisory authority:

EU Supervisory Authorities

You can find your local EU supervisory authority at: https://edpb.europa.eu/about-edpb/board/members_en

UK Supervisory Authority

The UK supervisory authority is the Information Commissioner's Office (ICO):

Website: https://ico.org.uk
Phone: 0303 123 1113

We encourage you to contact us first at privacy@becomingalpha.world so we can address your concerns directly.

Contact Information

For questions about this EU/UK GDPR Privacy Notice or to exercise your data subject rights:

Company: Becoming Alpha, Inc. (a Delaware corporation)

Address: 8000 Avalon Boulevard, Suite 100, Alpharetta, GA 30009, USA

Data Protection Officer / Privacy Email: privacy@becomingalpha.world

General Support: support@becomingalpha.world

For comprehensive information about our data processing practices, please see our main Privacy Policy.

For more contact options and additional ways to reach us, please visit our Contact page.